G.R. No. 148154. December 17, 2007 (Case Brief / Digest)

**Title:** *Republic of the Philippines vs. Sandiganbayan and Ferdinand R. Marcos, Jr.*

**Facts:** The Republic of the Philippines sought to recover alleged ill-gotten wealth amassed by the late President Ferdinand E. Marcos and his associates over his 20-year rule. The Presidential Commission on Good Government (PCGG) filed a Complaint in 1987 against Marcos, his wife Imelda, and associate Roman A. Cruz, Jr., alleging they stole public assets. The Complaint detailed various assets and demanded moral and exemplary damages. Despite efforts to summon the Marcoses, they failed to respond and were declared in default in 1989. Following Ferdinand Marcos’s death in 1989, his estate, represented by Imelda Marcos and their children, was substituted into the case. Imelda successfully moved to set aside the default order against her in 1992 but did not challenge the default status of her deceased husband.

Ferdinand “Bongbong” Marcos Jr., as executor of his father’s estate, later sought to engage in the proceedings by filing a motion for leave to file a responsive pleading in 1999. Despite the PCGG’s opposition, noting the unresolved default order against Ferdinand Marcos, the court allowed it, indicating an implicit lifting of the default status. Marcos Jr. then filed a motion for a bill of particulars, requesting more detailed allegations to craft a responsive pleading. The court granted this motion in 2000, and upon the government’s motion for reconsideration, upheld its decision in 2001, prompting the PCGG’s petition to the Supreme Court.

**Issues:** The case centered on whether the Sandiganbayan (anti-graft court) committed grave abuse of discretion by allowing a motion for a bill of particulars from the estate of Ferdinand Marcos, who was in default, and whether such motion was dilatory and without foundation.

**Court’s Decision:** The Supreme Court dismissed the PCGG’s petition, finding no grave abuse of discretion by the Sandiganbayan. It reasoned that the granting of motions for leave to file a responsive pleading effectively lifted the default order against Ferdinand Marcos, allowing his estate to participate in the case. The Court highlighted that procedural rules should be liberally construed to ensure justice and emphasized the preference to decide cases on their merits rather than on technicalities. The Court affirmed the Sandiganbayan’s resolutions and ordered the PCGG to prepare and file a bill of particulars.

**Doctrine:** This case reiterates the importance of procedural due process and the court’s discretion in managing proceedings to ensure fairness. It also underscores the principle that default judgments are disfavored and that parties should be given every opportunity to present their case.

**Class Notes:**
– **Default Judgment:** A legal party may be declared in default if they fail to respond to a pleading within the allotted time, but this does not remove their right to subsequent notices.
– **Motion for Bill of Particulars:** A procedural tool used to request more specific details in a pleading to adequately respond. It must be filed within the period for responding to the pleading that it seeks to clarify.
– **Lifting of Default Order:** The court has broad discretion to allow a defaulted party to participate in proceedings if justice so requires, even without a formal motion to lift the default.

**Historical Background:** This case is part of the broader efforts by the Philippine government to recover wealth alleged to have been ill-gotten by the Marcos family and their associates during Ferdinand Marcos’s presidency from 1965 to 1986. The legal battles have been prolonged and complex, often entangled with procedural disputes that challenge both the intricacies of law and the principles of justice and accountability.


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